Certain Countries of Europe_, by
Carroll D. Wright, Commissioner of Labour; together with the further
report for 1887 to 1906. The statistics contained in the former volume
have been analysed and interpreted in W. F. Willcox's _The Divorce
Problem: A Study in Statistics_ (Columbia University, New York, 1891,
1897). Further interpretations are contained in an article in the
_Political Science Quarterly_ for March 1893, entitled "A Study in
Vital Statistics." The best legal treatise is probably Bishop on
_Marriage, Divorce, and Judicial Separation_. See also J. P.
Lichtenberger, _Divorce: A Study in Social Causation_ (New York,
1909). (W. F. W.)

FOOTNOTES:

[1] In _Constantinidi_ v. _Constantinidi and Lance_ (1903), in which
both parties were guilty of misconduct, it was held by Sir Francis
Jeune (Lord St Helier) that where a wife has by her misconduct broken
up the home (the husband's misconduct not having conduced to the
wife's adultery) the court would exercise its discretion in favour of
the husband petitioner, and, further, the wife being a rich woman, it
was justifiable to give her husband a portion of her income, in order
to preserve to him the position he would have occupied as her
husband, the broad principle being that a guilty respondent should
not be allowed to profit by divorce. But further litigation
concerning this case occurred as to the variation of the marriage
settlements in favour of the husband, and the decision of the court
of appeal in July 1905 considerably modified the decision of Sir
Francis Jeune.--Ed. _E. B._

[2] It is to be noted that by a decision of the court of appeal in
_Harriman_ v. _Harriman_ in 1909, where a wife has been deserted by
her husband and has obtained a separation order within two years from
the time when the desertion commenced, she loses her right to plead
desertion under the Matrimonial Causes Act 1857, and is therefore not
entitled to a divorce after two years' desertion, upon proof of
adultery. See also _Dodd_ v. _Dodd_, 1906, 22 T. L. R. 484.

[3] In 1909 a Royal Commission was appointed to inquire into the law
of divorce, with special reference to the position of the poorer
classes.

[4] It is interesting to observe how, according to the latest
decisions of the House of Lords, cruelty, according to English law,
includes some but not oth